Partnership Taxation of LLCs: Basics for Non-Tax Lawyers

Why You Should Attend

Most multi-member LLCs, general partnerships and limited partnerships are taxable as partnerships under Subchapter K of the Internal Revenue Code. Partnership taxation provides these entities with unique federal tax advantages but also with significant tax risks. Even if you do not provide tax advice to your clients, you should have a basic understanding of partnership tax opportunities and risks in drafting partnership agreements for these entities and in handling transactions in which they are involved.

What You Will Learn

This 90-minute seminar is designed for non-tax lawyers. It will address, in plain English and with practical examples:

What the term “partnership” means under the relevant federal tax classification rules

All of the Subchapter K provisions most likely to be important to the above types of entities and their owners

The impact of the Tax Reform Act on the partnership taxation of LLCs and general and limited partnerships

A basic comparison of Subchapter K and Subchapter S for purposes of choice-of-entity and the drafting of inter-owner agreements

What non-tax lawyers should know about the radical new Bipartisan Budget Act partnership audit rules

Faculty

John M. Cunningham, Of Counsel, McLane Middleton, Manchester, NH John Cunningham is a former trial attorney in the Tax Division of the U.S. Treasury Department and a former member of the Foreign Trade and Tax Department of the international law firm of Baker McKenzie. His practice is focused on LLC formations, the conversion of non-LLC entities to LLC and the handling of disputes among LLC members and managers. He negotiated and obtained from the Internal Revenue Service the two leading private letter rulings covering statutory conversions of state-law business corporations taxable as S corporations to LLCs-- namely, PLRs 200524021 and 200548021. He teaches seminars on LLC law and tax to law firms, accounting firms and business groups nationwide. He chaired the committee that drafted the New Hampshire Revised Limited Liability Company Act.

Program Schedule

All Times Eastern

1:00 pm Partnership Taxation of LLCs: Basics for Non-Tax Lawyers

2:30 pm Adjournment

Total 60-minute hours of instruction: 1.5; Total 50 minute hours of instruction: 1.8

Suggested Prerequisite: Limited experience in subject matter

Educational Objective: Acquisition of knowledge and skills to develop proficiency as a practitioner; maintenance of professional competence as a practitioner; provision of information on recent legal developments

On-demand Course

Some jurisdictions limit the number of credits via on-demand (distance learning). We advise that you check your jurisdictions' rules regarding possible restrictions for on-demand or distance learning credit.

Important Note: On-demand courses cannot be consumed for partial credit. You must participate in the course in its entirety, regardless of length, to receive a certificate and credit.

AK (1.5 / 0)2/5/2021

AL (1.5 / 0)12/31/2018

AZ (1.5 / 0)2/5/2021

CA (1.5 / 0)2/5/2021

CO (1.8 / 0)2/5/2020

CT (1.5 / 0)2/5/2021

DE (1.5 / 0)2/12/2019

FL (2 / 0)8/5/2019

GA (1.5 / 0)2/5/2019

HI (1.5 / 0)2/5/2020

IA (1.5 / 0)2/12/2019

ID (1.5 / 0)2/5/2019

IL (1.5 / 0)2/5/2020

IN (1.5 / 0)2/12/2019

KY (1.5 / 0)6/30/2018

LA (1.5 / 0)2/4/2019

ME (1.5 / 0)2/5/2021

MN (1.5 / 0)2/5/2020

MO (1.8 / 0)2/5/2021

MS (1.5 / 0)2/5/2019

MT (1.5 / 0)2/5/2021

NC (1.5 / 0)12/31/2018

ND (1.5 / 0)2/5/2021

NE (1.5 / 0)2/4/2020

NH (1.5 / 0)6/30/2018

NJ (1.8 / 0)2/5/2019

NM (1.5 / 0)2/5/2021

NV (1.5 / 0)2/5/2021

NY (1.5 / 0)2/5/2021

OH (1.5 / 0)12/31/2018

OK (2 / 0)2/12/2019

OR (1.5 / 0)2/5/2021

PA (1.5 / 0)2/5/2020

PR (1.5 / 0)2/5/2021

RI (1.5 / 0)2/5/2021

SC (1.5 / 0)12/31/2018

TN (1.5 / 0)2/5/2019

TX (1.5 / 0)1/31/2019

UT (1.5 / 0)12/31/2018

VA (1.5 / 0)11/1/2018

VI (1.8 / 0)2/5/2021

VT (1.5 / 0)2/5/2021

WA (1.5 / 0)2/5/2023

WI (1.5 / 0)2/5/2021

WV (1.8 / 0)2/5/2021

WY (1.5 / 0)2/5/2021

Telephone Seminar

AK (1.5 / 0)

AL (1.5 / 0)

AR (1.5 / 0)

AZ (1.5 / 0)

CA (1.5 / 0)

CO (1.8 / 0)

CT (1.5 / 0)

DE (1.5 / 0)

FL (2 / 0)

GA (1.5 / 0)

HI (1.5 / 0)

IA (1.5 / 0)

ID (1.5 / 0)

IL (1.5 / 0)

IN (1.5 / 0)

KS (1.5 / 0)

KY (1.5 / 0)

LA (1.5 / 0)

ME (1.5 / 0)

MN (1.5 / 0)

MO (1.8 / 0)

MS (1.5 / 0)

MT (1.5 / 0)

NC (1.5 / 0)

ND (1.5 / 0)

NE (1.5 / 0)

NH (1.5 / 0)

NJ (1.8 / 0)

NM (1.5 / 0)

NV (1.5 / 0)

NY (1.5 / 0)

OK (2 / 0)

OR (1.5 / 0)

PA (1.5 / 0)

PR (1.5 / 0)

RI (1.5 / 0)

SC (1.5 / 0)

TN (1.5 / 0)

TX (1.5 / 0)

UT (1.5 / 0)

VA (1.5 / 0)

VI (1.8 / 0)

VT (1.5 / 0)

WA (1.5 / 0)

WI (1.5 / 0)

WV (1.8 / 0)

WY (1.5 / 0)

Webcast

Several jurisdictions limit the number of credits to be taken via webcasts. Please check with your state regulator for possible limits in your jurisdiction.

AK (1.5 / 0)

AL (1.5 / 0)

AR (1.5 / 0)

AZ (1.5 / 0)

CA (1.5 / 0)

CO (1.8 / 0)

CPE (1.5 / 0)

CT (1.5 / 0)

DE (1.5 / 0)

FL (2 / 0)

GA (1.5 / 0)

HI (1.5 / 0)

IA (1.5 / 0)

ID (1.5 / 0)

IL (1.5 / 0)

IN (1.5 / 0)

KS (1.5 / 0)

KY (1.5 / 0)

LA (1.5 / 0)

ME (1.5 / 0)

MN (1.5 / 0)

MO (1.8 / 0)

MS (1.5 / 0)

MT (1.5 / 0)

NC (1.5 / 0)

ND (1.5 / 0)

NE (1.5 / 0)

NH (1.5 / 0)

NJ (1.8 / 0)

NM (1.5 / 0)

NV (1.5 / 0)

NY (1.5 / 0)

OH (1.5 / 0)

OK (2 / 0)

OR (1.5 / 0)

PA (1.5 / 0)

PR (1.5 / 0)

RI (1.5 / 0)

SC (1.5 / 0)

TN (1.5 / 0)

TX (1.5 / 0)

UT (1.5 / 0)

VA (1.5 / 0)

VI (1.8 / 0)

VT (1.5 / 0)

WA (1.5 / 0)

WI (1.5 / 0)

WV (1.8 / 0)

WY (1.5 / 0)

Partnership Taxation of LLCs: Basics for Non-Tax Lawyers (Audio)

Price: $199.00

Printed Coursebook

For further information about the program, please use the links on the lefthand side under "Course Details".